Quarterly Reporting

Date: February 22, 2006

SIAS has submitted to the Council on Corporate Disclosure and Governance its response to the Consultation Paper in connection with CCDG’s Review of the Quarterly Reporting Requirement.

SIAS takes the view that more information is better than less information for the investor. As such, we are generally in favour of quarterly reporting.

However, we also recognize the considerable cost involved in producing quarterly reports – both the dollar cost of additional staff and assistance from audit firms as well as the cost in terms of management time and attention that could be channeled toward other business activities. We are also mindful that this cost is ultimately borne by the company’s shareholders.

Balancing the desirability of quarterly reports and the cost involved, we are of the view that larger companies should continue to be required to issue quarterly reports. For smaller companies, while quarterly reports should not be mandatory, the companies should be encouraged to issue them as a best practice.

Also, we propose that for companies exempted from quarterly reporting, they should be required at the end of the first and third quarters to declare:

• That there are no reportable developments that have not already been disclosed, and
• That there is no significant change to the prospects for the company as previously announced.

This requirement will also encourage boards – some of which meet only twice a year to review and approve the semi-annual results announcements – to convene at least four times a year.

Mr David Gerald J.
President & CEO
Securities Investors Association (Singapore)